Russell-Cooke
6 Experts
1 Contributions by Russell-Cooke
PRACTICE NOTES
Many people have cross-border ties that must be factored into succession planning. They may have been born outside England and Wales or hold property in overseas jurisdictions. As these connections can evolve, it is vital to review arrangements regularly, especially when personal circumstances shift. For guidance on foreign jurisdictions, consult the Foreign jurisdictions—overview and the International Q&A guides—Private Client—overview sub-topics. The International Comparator Tool can also assist when contrasting legal frameworks across multiple jurisdictions.
Separate Wills in various jurisdictions
Traditionally, clients have been advised to put in place a distinct Will for each jurisdiction where assets are situated. This can prevent delays linked to waiting for probate processes abroad and reduce the need for notarised translations and complications with Affidavits of Law. Nonetheless, this approach is not universally suitable. When advising, ensure the client addresses key points such as:
Where do they intend to
Private Client
2 Contributions by Russell-Cooke Experts
PRACTICE NOTES
Tax domicile (domicile fiscal)
Persons whose domicile fiscal is in France are liable to French taxation on their worldwide income. Here, domicile is understood in the civil law sense and typically aligns with an individual’s habitual residence.
Tax household (Foyer fiscal)
The Foyer fiscal covers spouses or civil partners together with their dependent children, and, unless they are living apart, the unit is assessed jointly for tax.
Statutory domicile test
Article 4 B of the Code général des impôts (CGI) sets out a statutory domicile test. A person is treated as domiciled in France for tax wherever any of the following apply:
their foyer (family home) or lieu de séjour principal (main abode) is located in France
they carry on a professional activity in France (employed or self-employed), unless they can demonstrate that such activity is merely ancillary
the centre of their economic interest is located in
Private Client
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